This policy is designed to give guidance to all UCL staff and students on the expected standards of behaviour when working with children, young people and vulnerable adults, and our responsibilities and processes in reporting any concerns. Additional guidance should be sought locally for specific jobs or activities, especially where working with young children or in a personal or private environment.

1 Introduction

UCL is committed to safeguarding the safety and well being of vulnerable groups involved in UCL activities. As part of this commitment, UCL wishes to ensure that everyone who takes part in activities, as staff or participants (including volunteers), understands the boundaries of appropriate behaviour.

These guidelines are designed as a reference guide to the safeguarding measures which UCL expects its employees and students to observe when they have contact with vulnerable groups.

These guidelines should be observed in addition to any job or activity specific guidance issued by departments or activity co-ordinators.

The Disclosure and Barring Service (DBS) was established under the Protection of Freedoms Act 2012 and merges the functions previously carried out by the Criminal Records Bureau (CRB) and Independent Safeguarding Authority (ISA). Under the provisions of the Safeguarding Vulnerable Groups Act 2006, the DBS will make decisions about who should be barred from working with vulnerable groups.

The new legal definition of regulated activity for adults no longer uses the term ‘vulnerable adults’ and no longer requires the activity to meet a minimum frequency threshold. The definition now focuses on the nature of activities, which if required by an adult, will define them to be vulnerable. Staff and managers of staff providing the following activities will be conducting regulated activity:

Health care – any health care professional providing health care to an adult or anyone who provides health care to an adult under the supervision of a health care professional.

Personal care – providing assistance, supervision or advice in relation to activities including eating and washing.

Social care lives in residential accommodation including sheltered housing and a care home

Assistance with cash, bills or shopping

Assistance in the conduct of a persons own affairs

Transporting an adult because of their age, disability or illness to or from their home and a place where they will receive health care, personal care or social care.

4 Principles

A relationship of trust exists where a member of staff, a student, or a volunteer is in a position of power or influence over a vulnerable person by virtue of the work or nature of the activity being undertaken.

UCL believes that all vulnerable people have the right to be:

protected from abuse and safe in the activities that they, or their parents and carers, choose;

If you work in a position of trust with vulnerable people, whether on a paid or voluntary basis or as part of a placement, research project or programme of study, you must familiarise yourself with these guidelines. Adhering to this guidance will help you to safeguard the people you are working with and may help you to avoid placing yourself in a situation which could be misinterpreted.

You may also be required to have disclosure and barring service checks (DBS) (see section 11 below) and may have to undertake training in safeguarding awareness.

If you work in research and your research project involves working with vulnerable groups, you will require ethics approval before commencing the research. For Non-NHS research studies, please visit the webpages of the UCL Research Ethics Committee and for NHS research studies, you will need to seek ethics approval via the National Research Ethics Service (NRES) or contact the Joint UCLH/UCL Biomedical Research Unit for appropriate advice.

UCL will take appropriate action against breaches of these guidelines, in accordance with its existing disciplinary procedures and legal obligations.

In your position of trust it is important that you demonstrate exemplary behaviour. Remember that someone else might misinterpret your actions, no matter how well intentioned. You should always give due consideration as to what is an appropriate environment and what is appropriate conduct in relation to the activities you are undertaking. Furthermore, you should:

treat all people including students, staff and visitors with respect and with due regard to cultural differences;

act as an appropriate role model and provide an example you wish others to follow;

allow vulnerable groups to use inappropriate language without challenging it;

enter into a physical 'adult' relationship with a vulnerable person to whom you are in a position of trust, even if they give their consent. This would be a criminal offence if the relationship was with a child2;

You may not be sufficiently familiar with working with vulnerable groups to be 100% confident in recognising abuse, but you may come across something which concerns you or just 'does not seem quite right'. Abuse can take different forms and includes physical abuse, sexual abuse, emotional abuse as well as neglect and bullying. Abuse can have serious and long term effects in terms of development, health and well being including to self esteem and self image.

It is not the place of UCL employees or students to make a judgement about whether abuse has occurred; this is the remit of Social Services. However, you have a duty and responsibility as someone working with vulnerable groups to report any concerns to the appropriate officer.

The Children and Vulnerable Adults Safeguarding Policy can be found here. This policy states that “if a member of the UCL community becomes aware that a student may be vulnerable, they should alert the Director of Student Support and Wellbeing as soon as possible by competing the UCL Student of Concern form – www.ucl.ac.uk/registry-admin/support/open. The Director will then liaise with the appropriate internal stakeholders and/or external agencies to ensure effective support is put in place for the student.

Where any concern is reported, the nominated safeguarding officer will notify the Vice-Provost (Operations) of the nature of the concern and action taken. The Vice-Provost (Operations) will ensure that relevant colleagues are notified and appropriate action taken.

Any concerns, suspicions or allegations of abuse or inappropriate behaviour will be taken very seriously by UCL and responded to appropriately. This process may involve Social Services, the Police and/or the UCL Staff or Student Disciplinary procedures.

UCL has a legal obligation to refer to the Independent Safeguarding Authority where we remove an individual (including volunteers or other participants) from the workplace or would or might have removed him/her (if the individual has already left prior to the conclusion of the disciplinary procedure), someone who has caused harm or would have or poses a risk of harm to a vulnerable person.

Non compliance with this duty is regarded as a criminal offence and may be committed by a corporate body as a regulated activity provider, an officer of the body, or a person acting on behalf of a regulated activity provider.

You must therefore immediately report this information to a UCL Safeguarding Contact who should read the 'duty to refer – additional guidance for safeguarding contacts'. If a 'duty to refer' is appropriate, the Safeguarding Contact should in the first instance consult Camden Social Services and following their advice inform the DBS (see https://www.gov.uk/government/publications/dbs-referrals-form-and-guidance).

Accidents
If a vulnerable person is accidentally hurt whilst they are under your supervision or care, you should report the incident as quickly as possible to the activity co-ordinator or your Departmental Safety Officer.

Other things to report

there is a concern that a relationship is developing which may be an abuse of trust;

you are worried that a vulnerable person is becoming attracted to you;

you are worried that a vulnerable person is becoming attracted to a colleague who supervises or works with them;

you think a vulnerable person has misunderstood or misinterprets something you have done;

you have been required to physically restrain a vulnerable person to prevent them from harming themselves or another or from causing significant damage to property;

a vulnerable person tells you they are being abused or describes experiences you believe may constitute abuse;

Members of UCL staff planning to work in a position of trust in a 'regulated' position must have an enhanced DBS check before they start work in this position. See the DBS checks and Criminal Convictions procedure for further details.

To arrange a DBS check for staff, you should contact:

HR Employment Contract Administration Team, UCL Human Resources

Most UCL students who will be participating in an activity which places them in a position of trust will be notified by their department or activity co-ordinator of how to arrange their DBS check.

Any student due to participate in an activity which places them in a position of trust who has not been given advice by their department or activity co-ordinator should arrange their DBS check by contacting:

For some UCL staff and students, safeguarding training is mandatory and must be completed before they will be allowed to start work in a position of trust. These individuals will be notified of the need to undertake training and will be advised of how the training will be delivered to them.

For members of staff, the 'Child Protection in Education' online training module is recommended. The training provides, among other things, basic awareness of the various types of abuse and the different cultural contexts of behaviour.

Training for UCL students undertaking voluntary work or placements involving contact with children or young people undertaken as part of their programme of study may be via the online training module, or may be delivered directly by departmental or activity co-ordinators. Students due to undertake work in a position of trust will be told which training route is appropriate for them.

Other members of the UCL community may have contact with children or young people on a more casual basis, in which case training is not essential providing they understand and adhere to the guidelines above. Any UCL employee or student in this category who feels they require further safeguarding advice should either contact the co-ordinator of the activity in which they are involved or the relevant officer below:

Footnotes1 UK Statute Law defines a child as a person under the age of 18 years. 'Young person' and 'Young people' are not legal terms, but for the purposes of this Policy document describe those who might not perceive themselves as children, but are still within the age range of the legal definition of a child.

2 Sexual Offences Act 2000 and the Sexual Offences (Amendment) Act 2003: It is a criminal offence for a person in a position of trust to engage in any sexual activity with a person aged under 18 with whom they have a relationship of trust, even if the young person is over the age of sexual consent and/or the relationship is consensual